QUESTION PRESENTED
               You requested a legal opinion regarding whether the Social Security Administration
                  (SSA) should approve K~’s request for a replacement social security number (SSN) card
                  based on a name change due to marriage. K~ presented as evidence of her name change
                  a Nigerian marriage certificate.
               
               SHORT ANSWER
               SSA should not approve K~’s request for a replacement SSN card, because a Nigerian
                  marriage document is not an acceptable name change document under SSA policy. As a
                  result, if K~ still wishes to change her name on her SSN, she will need to submit
                  another document that is acceptable evidence of a name change, as well as meet the
                  other requirements for processing a name change on the SSN.
               
               BACKGROUND
               K~ is a resident of Wisconsin. On March XX, 2017, she married O~ in Lagos, Nigeria.
                  A Certificate of Marriage was issued by the Federal Republic of Nigeria, Ministry
                  of Interior.
               
               On March XX, 2017, K~ visited the R~, Wisconsin Field Office and requested a replacement
                  SSN card reflecting her married surname, based on her marriage to O~. In support of
                  her request, K~ submitted the Nigerian marriage certificate, a Wisconsin driver’s
                  license, a United States passport, and a Nigerian visa. The name listed on the passport
                  and visa is K~. We were unable to read the name listed on the driver’s license due
                  to the poor quality of the copied image.
               
               DISCUSSION
               In order to obtain a name change on a number holder’s SSN, the number holder must
                  submit evidence of the name change event, the new name, and the number holder’s identity
                  as shown on the latest Numident record. See POMS RM 10212.015. Where, as here, the name change event is a foreign marriage, agency policy instructs
                  that all foreign marriage documents must be evaluated under the guidelines on reviewing
                  SSN evidence. Specifically, SSA will accept a foreign marriage document that meets
                  the SSN evidence guidelines as evidence of a name change. See POMS RM 10212.050A.
               
               The POMS provision governing evidence from Nigeria states that SSA does not accept
                  evidence of vital statistics events from Nigeria at face value, because vital statistics
                  records from Nigeria are unreliable and not sufficient evidence of a vital statistics
                  event. See POMS GN 00307.727B. We consulted with the Office of Program Law and were informed
                  that the Office of International Policy (OIP) is responsible for maintaining the POMS
                  on foreign evidence, and engages in a substantial amount of development with the Foreign
                  Service Post before making decisions. OIP revisits the POMS on foreign evidence every
                  3-5 years to reassess whether the evidence standards for particular countries have
                  changed. Thus, unless and until OIP changes the policy regarding Nigerian evidence,
                  a Nigerian marriage document is inadequate evidence of a name change for enumeration
                  purposes.
               
               When a document is determined to be unacceptable, SSA must ask the applicant to provide
                  other documentation. See POMS RM 10210.210 (step 2). As a result, an applicant who wishes to change her name on her SSN based
                  on a Nigerian marriage may have to provide another document that is acceptable evidence
                  of a name change, based on an event listed in POMS RM 10212.010.
               
               Here, K~ submitted a Certificate of Marriage from Nigeria in support of her request
                  for a name change on her SSN. As discussed above, this document does not meet the
                  SSN evidence guidelines as evidence of a name change. Therefore, it is not an acceptable
                  name change document under SSA policy. If K~ still wishes to change her name on her
                  SSN, she may obtain a U.S. court order of name change. See POMS RM 10212.080, RM 10212.085. Wisconsin law provides that any resident of the state (except for sex offenders)
                  may, if no sufficient cause is shown to the contrary, have her name changed by order
                  of the court. See Wis. Stat. § 786.36. Alternatively, K~ may be able to obtain a U.S. marriage certificate.
                  See POMS RM 10212.025, RM 10212.055. She would also need to submit evidence of her identity, as required by POMS RI 10212.015D.
               
               CONCLUSION
               For the reasons discussed above, we conclude that SSA should not approve K~’s request
                  for a replacement SSN card based on a name change resulting from her marriage in Nigeria.
                  Specifically, the Nigerian marriage document she submitted is not an acceptable name
                  change document under SSA policy.
               
               Kathryn Caldwell
               Regional Chief Counsel, Region V
               By Cristine Bautista
               Senior Counsel